From: Robert Bengtson [rb@bengtsonphoto.com]
Sent: Monday, December 02, 2002 10:26 PM
To: rule-comments@sec.gov
Subject: Re: File Numbers S7-36-02 and S7-38-02
Mr. Jonathan G. Katz, Secretary
Securities and Exchange Commission
450 Fifth Street NW,
Washington, DC 20549-0609
Dear Secretary Katz:
The issue of voting disclosure has recently come to my attention. As an
individual investor, I am strongly supporting the Security and Exchange
Commission's recently proposed rules regarding proxy voting guidelines and
vote disclosure by mutual funds and investment advisers, File Numbers
S7-36-02 and S7-38-02. With nearly all my investments managed by mutual
funds, I would significantly benefit from having the information of how the
institutions managing my money are voting proxies on my behalf. It would so
clearly be creating a situation that would keep the best intentions in the
forefront of action. This information, of course, would enable me to choose
a mutual fund manager that is voting proxies in line with my values. From
corporate governance to social and environmental issues, to name a few.
To empower individual investors, I urge the SEC to require that disclosure
of proxy votes and voting guidelines be directly disclosed on mutual fund
and investment advisers' web sites, in addition to the SEC's web site. I
also believe print copies should be made available to those investors that
do not have access to the web, or for small companies covered by the rule
that do not have a website. Additionally, I would like to see more specific
guidance from the SEC on what should be covered in a proxy voting policy or
set of guidelines. Hundreds of resolutions are filed by shareholders each
year, on a range of issues, and voting policies should be broad enough to
reflect the diversity of concerns coming to a vote.
It's evident that consumer confidence is at an all-time low, which is really
no surprise given what continues to surface in the news regarding the degree
to which greed and self-interest has come at the expense of the investor.
I'm, of course, therefore pretty concerned about current potential conflicts
of interest that may influence my money managers to vote proxies in ways
that do not reflect the interests of individual shareholders. I believe
full disclosure of proxy voting (which some socially responsible investment
funds already do, of course!) is an easy, but critical, step in protecting
the interests of individual shareholders and addressing some of the
corporate scandals of the past year.
Thank you for the opportunity to comment on the proposed rules. May the
right ruling serve to move forward in our economy with integrity and
authenticity and pride.
Sincerely,
- Robert Bengtson
____________________________________________________
Robert Bengtson
Bengtson Photography
200 Gate 5 Road, Suite 109
Sausalito, CA 94965 USA
Studio (1.415) 332.7841
Fax (1.415) 332.7847
rb@bengtsonphoto.com
http://www.bengtsonphoto.com